Memorandum by Brethren's Gospel Trusts
(LGC 16)
1. SUMMARY
1.1 Brethren's Gospel Trusts operate worldwide
and throughout Britain, where they are accepted as charitable
organisations, responsible for the provision and maintenance of
Gospel Halls.
1.2 We are aware of recent research undertaken
for the Scottish Executive, which has suggested that responses
to Local Government Consultations are unrepresentative of the
population as a whole and local authorities tend to receive inaccurate
views. We support the Scottish Executive Report conclusions, based
on our recent experiences within England.
1.3 Our recent experience suggests that
whilst Local Government Officers generally have the ability to
afford unrepresentative views less weight in an unbiased assessment
of planning proposals, for instance, this is often not shared
by elected Members who often appear to give such views added weight
due to short-term electoral consequences.
1.4 Notwithstanding the above, we would
commend the Government's recent initiatives in promoting public
involvement and wider consultation within the Planning system
generally and the modernised Local Development Framework process,
which seeks to encourage wider Local Government Consultation including
"hard to reach" groups such as Faith Groups.
1.5 Whilst the new process is at an early
stage, preliminary responses to individual Brethren's Gospel Trusts
appears to be encouraging, leading to hopes that the recent reforms
will be more effective in ensuring a wider engagement with the
population.
2. INTRODUCTION
2.1 We represent Charitable Gospel Trusts
established by Christians commonly known as "Brethren",
who have long established and growing congregations in many towns
and cities throughout Britain.
2.2 There are currently about 100 assemblies
of "Brethren" in Britain. Each assembly will typically
comprise a "City" hall as a focal gathering point, together
with several "local" halls to serve a more limited local
function in a neighbourhood.
2.3 There are about 400 halls throughout
Britain with about 15,000 communicants. Numbers continue to increase
and "planting" of new assemblies and an ongoing need
for new halls in existing areas continues. As a result of these
needs, our clients are active participants in the planning process,
both in pursuing an appropriate development Plan policy framework
and in the planning Development Control process (ie planning applications).
2.4 Brethren, including Trustees of the
charitable Gospel Trusts, welcome the opportunities to testify
to authorities at national and local level in order to seek a
sympathetic understanding of their needs, and special limitations.
3. LOCAL GOVERNMENT
CONSULTATION
3.1 We note the Committee inquiry seeks
to focus on consultation by local authorities on the delivery
of their mainstream services, regeneration initiatives and planning
functions.
3.2 Brethren's Gospel Trusts, represent
a cross-section of the community with diverse personal backgrounds,
circumstances and wider business interests—who benefit from
mainstream services and to some extent regeneration initiatives.
Nonetheless, the Trustees limited remit impacts primarily on the
planning functions of local government, resulting from planning
applications for new Places of Worship and participation in the
planning policy process.
3.3 Planning and Community Involvement in
Scotland
The above subject research report for the Scottish
Executive was reviewed in "Planning"—23 July 2004.
The report conclusions were summarised as follows:
(a) people who respond to planning consultations
are unrepresentative of the population, being largely middle-aged
and elderly;
(b) most people "feel completely disconnected
from the planning process";
(c) the public judge local authorities and
developers to be poor at consultation and supplying information;
(d) as a result "nimbies" are allowed
to control the consultation process and small issue objectors
dominate agendas "to the exclusion of the rest of the community";
(e) local authorities may also be receiving
inaccurate views on the acceptability of a proposal.
3.4 Our recent experiences in England and
those of our individual Trusts suggest to us that the conclusions
of the Scottish Executive research report are also typical of
England as well as Scotland.
3.5 We are of the opinion that local authorities
are indeed poor at consultation and supplying information. Consultations
are often limited to members of the community who may be immediately
directly affected by a proposal, without regard to the wider benefits
which could accrue from a proposal. In many cases formal or informal
residents associations will over-react with a block of standard
responses largely based on incomplete information or wholly false
assumptions which lead to public alarm. In many cases this fear
of the unknown leads to objections which can readily be refuted
or clarified.
3.6 As noted above, many experienced and
knowledgeable 1ocal government officers have the ability to afford
unrepresentative and irrelevant views less weight when making
an unbiased technical assessment of the relevant planning application.
3.7 Nevertheless, there is widespread concern
that elected Members often appear to give third party views added
weight. Rather than rely largely on officers' expertise, such
Members appear to be seeking to be popular with their electorate,
giving rise to concerns that short-term electoral consequences
carry more weight than a formal planning assessment. In part,
we submit, this may well stem from a lack of understanding of
the limitations of the public consultations exercise.
3.8 In some local authorities, the impression
given is that Council Officers and members alike regard the consultation
process as a necessary evil but the results of consultation do
not add significantly to the quality of decision making. In many
cases, a poor level of public response can contribute to the lack
of effectiveness of the consultations.
3.9 We readily acknowledge that public consultation
forms only part of the local authority decision making process.
Consultations with a wide range of internal and external statutory
consultees form another important input to the process. However,
it is not infrequent for a decision to reflect ill informed public
views in the face of contrary technical evidence on traffic levels
or speeds, or on Noise Impacts for example.
3.10 In the current and recent past, the
Planning functions of most local authorities do not make public
consultation part of a continuing process of communication, information
dissemination and participation.
3.11 In the planning policy process, procedures
have been such that most public consultation has been undertaken
in sporadic events with publication of excessively detailed and
technical documentation at lengthy intervals. To the public, participation
in a meaningful way is often difficult and there is widespread
evidence of "consultation fatigue", especially with
the general public.
3.12 We are unaware of any formal development
of best practice in the consultation process; as distinct from
statutory regulations and Planning Policy Statements. We are concerned
that ODPM are deliberately concentrating on process as distinct
from practice in current and recent guidance. We would support
best practice guidance publication and application in order to
make local government consultation and decision making more uniformly
effective.
3.13 A wide variety of public consultation
methods are employed by local authorities including:
(a) public exhibitions for major proposals/policy
documents;
(b) free newsletters to be distributed to
local residents;
(c) targeted mail shots and notices to local
residents and appropriate organisations;
(d) newspaper articles, advertisements or
public notices;
(e) local authority magazines, issued by
post to all residents;
(f) site notices at or close to planning
application sites.
3.14 Notwithstanding all these mediums,
we believe that there remain sections of the general public who
fail to appreciate the significance of consultation until the
relevant period has expired or who are insufficiently motivated
to respond. To this extent the "effectiveness" of public
consultation must be questioned.
3.15 Furthermore, there are distinct groups
of typical participants who are generally reached and others who
are not. We are uncertain to what extent this is an endemic limitation
of any form of consultation caused by the inevitable wide variations
of sensitivity of a wide audience or conversely by an inevitable
tendency for consultations to attract limited but active special
interest, groups. In this context, we are aware that "Faith
Groups" have been amongst "hard to reach organisations".
For this reason, we are actively seeking to alert our local Gospel
Halls Trusts to the need to engage with their local authority
and to participate in forthcoming "Statements of Community
Involvement" and the Local Development Framework process.
We recognise that this is a two-way process involving motivation
of local Trustees to make contact with their local authority and
the local authorities positively responding to such contacts in
the light of recent Government guidance.
3.16 As noted above, we would commend the
Government's recent initiatives and the statutory recognition
of the need to promote public involvement and wider consultation
within the Planning System generally and the modernised Local
Development Framework process, including "hard to reach"
groups.
3.17 We acknowledge that the new process
is at an early stage, however preliminary responses to individual
local Gospel Hall Trusts appears to be encouraging, leading us
to hopes that the recent reforms will be more effective in ensuring
a wider engagement with the population as a whole. How effectively
this will promote decision making remains to be tested in practice.
Furthermore, we are concerned at any ongoing "consultation
fatigue" diminishing the effectiveness of the reforms in
the fullness of time.
3.18 We have active and ongoing engagement
with the new cabinet structures in Local Government, but have
no definitive view on whether this has enhanced or inhibited consultation
and the involvement of constituents in decision making.
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